L44 160527 001 Proprietary Information and Critical Energy Infrastructure Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 1, 2, 3, and 8 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-091 May 27, 2016 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296 Subject: Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 18, Responses to Requests for Additional Information and Updates Associated with Interconnection System Impact Study Modifications References: 1. Letter from TVA to NRC, CNL-15-169, “Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU),” dated September 21, 2015 (ML15282A152) 2. Letter from NRC to TVA, “Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743),” dated April 4, 2016 (ML16064A286) 3. Letter from TVA to NRC, CNL-16-075, “Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 13, Responses to Requests for Additional Information,” dated April 22, 2016 4. Letter from TVA to NRC, CNL-15-261, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 3, Interconnection System Impact Study Information," dated December 18, 2015 (ML15355A413) U.S. Nuclear Regulatory Commission CNL-16-091 Page 2 May 27, 2016 5. Letter from TVA to NRC, CNL-16-023, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 4, Response to Requests for Additional Information," dated February 16, 2016 (ML16049A248) By the Reference 1 letter, Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for the Extended Power Uprate (EPU) of Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3. The proposed LAR modifies the renewed operating licenses to increase the maximum authorized core thermal power level from the current licensed thermal power of 3458 megawatts to 3952 megawatts. During their technical review of the LAR, the Nuclear Regulatory Commission (NRC) identified the need for additional information. The Reference 2 letter provided NRC Requests for Additional Information (RAI) related to the environmental review of the BFN EPU LAR. The Reference 3 letter provides the responses to the RAIs included in the Reference 2 letter, with the exception of the responses to NRC RAIs RERP-GE-RAI 2 and RERP-GE-RAI 4. NRC RAIs RERP-GE-RAI 2 and RERP-GE-RAI 4 involve providing environmental information associated with transmission system upgrades identified in the interconnection system impact study (SIS). However, due to changes in the modifications associated with these transmission system upgrades and the time needed to achieve alignment and agreement among TVA stakeholders regarding these changes to the modifications, the due date for the responses to NRC RAIs RERP-GE-RAI 2 and RERP-GE-RAI 4 and the other revised portions of the BFN EPU LAR impacted by the changes to the transmission system upgrades was extended to June 10, 2016, per communication with the NRC Project Manager. TVA performed an interconnection SIS for the EPU of all three BFN units that was submitted to the NRC on December 18, 2015 (Reference 4). This interconnection SIS identified the need to replace six breaker failure relays at BFN, install 774 megavolt-ampere reactive (MVAR) capacitor banks in four locations throughout the TVA transmission system, and construct a new 500 kilovolt (kV) transmission line. Further study and evaluation of the transmission system modifications and alternatives resulted in a revision of the interconnection SIS. The revised interconnection SIS identifies the need to replace six breaker failure relays, install 764 MVAR capacitor banks in five locations throughout the TVA transmission system, and modify the excitation system of all three BFN main generators. Therefore, the new 500 kV transmission line will no longer be required to support BFN EPU and the impact of a new excitation system will be addressed in this BFN EPU LAR supplement in lieu of the transmission line. Enclosure 1 of this letter provides Revision 1 of the interconnection SIS. Enclosure 1 supersedes and replaces the interconnection SIS submitted by the Reference 4 letter, dated December 18, 2015. Enclosure 2 of this letter provides the updated BFN EPU Transmission System Stability Evaluation that has been revised to reflect the modifications resulting from the final interconnection SIS provided in Enclosure 1 of this letter. The BFN EPU Transmission System Stability Evaluation study evaluates the effect of BFN operation at EPU conditions with respect to continued compliance with 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 17, U.S. Nuclear Regulatory Commission CNL-16-091 Page 3 May 27, 2016 Electric Power Systems. Enclosure 2 supersedes and replaces Attachment 43 of the BFN EPU LAR submitted by the Reference 4 letter, dated December 18, 2015. Enclosure 3 of this letter provides the updated response (Revision 1) to the NRC RAI EEEB-RAI 1. The update has been made to reflect the changes to the transmission system upgrades included in Revision 1 of the interconnection SIS. Enclosure 4 of this letter provides a public version of Revision 1 of NRC RAI EEEB-RAI 1 and updated response, with critical energy infrastructure information removed. Enclosures 3 and 4 of this letter supersede and replace Enclosures 3 and 4 of the Reference 5 letter, dated February 16, 2016. Enclosure 5 of this letter provides the responses to NRC RAIs RERP-GE 2 and RERP-GE-4. Enclosure 5 of this letter also provides the updated response (Revision 1) to NRC RAI RERP-GE 3. The update has been made to reflect the changes to the transmission system upgrades included in Revision 1 of the interconnection SIS. Revision 1 of NRC RAI RERP-GE 3 response provided in Enclosure 5 of this letter supersedes and replaces the response to NRC RAI RERP-GE 3 provided in the Reference 3 letter, dated April 22, 2016. Enclosure 6 of this letter provides Revision 1 to the BFN EPU Supplemental Environmental Report. The revised BFN EPU Supplemental Environmental Report reflects the transmission system upgrades included in Revision 1 of the interconnection SIS. Enclosure 6 supersedes and replaces Attachment 42 of the BFN EPU LAR (Reference 1), dated September 21, 2015. Enclosure 7 of this letter provides a supplement to the BFN EPU Probabilistic Risk Assessment. This supplement to the BFN EPU Probabilistic Risk Assessment addresses the effect of the main generator excitation system upgrade included in Revision 1 of the interconnection SIS. Enclosure 7 supplements, but does not supersede, Attachment 44 of the BFN EPU LAR (Reference 1), dated September 21, 2015. Enclosure 8 of this letter provides a supplement to Section 2.5.1.2.2 of the Power Uprate Safety Analysis Report (PUSAR) (NEDC-33860P, Revision 0). The supplement addresses the effect of the main generator excitation system upgrade included in Revision 1 of the interconnection SIS. Enclosure 9 of this letter provides a public version of the supplement to Section 2.5.1.2.2 of the Power Uprate Safety Analysis Report (PUSAR) (NEDO-33860, Revision 0). Enclosures 8 and 9 supersede and replace Section 2.5.1.2.2 of Attachments 6 and 7, respectively, of the BFN EPU LAR (Reference 1), dated September 21, 2015. Enclosure 10 of this letter provides Revision 1 to the BFN EPU List and Status of Plant Modifications. The BFN EPU List and Status of Modifications is revised to reflect the main generator excitation system upgrade included in Revision 1 of the interconnection SIS and modifications that have been completed since the BFN EPU LAR was submitted. Enclosure 10 supersedes and replaces Attachment 47 of the BFN EPU LAR (Reference 1), dated September 21, 2015. Enclosures 1, 2, and 3 contain critical energy infrastructure information that is considered sensitive, unclassified (non-safeguard) information. As a result, TVA requests that U.S. Nuclear Regulatory Commission CNL-16-091 Page4 May 27, 2016 Enclosures 1, 2, and 3 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390(d)(1 ). As stated above, Enclosure 8 to this letter provides a supplement to the PUSAR. GE-Hitachi Nuclear Energy Americas LLC (GEH) consider portions of the information provided in Enclosure 8 of this letter to be proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390, Public inspections, exemptions, requests for withholding. An affidavit for withholding information, executed by GEH, is provided in Enclosure 11. Enclosure 9 is a non-proprietary version of the supplement to the PUSAR provided in Enclosure 8. Therefore, on behalf of GEH, TVA requests that Enclosure 8 be withheld from public disclosure in accordance with the GEH affidavits and the provisions of 10 CFR 2.390. TVA has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in the Reference 1 letter. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed license amendment.